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Manor Royal BID responds to Davies Airport Commission

Dear Sir Howard

Ref: Airports Commission Consultation Response

We write on
behalf of the Manor Royal Business Improvement District (BID) Company, (MRBD) Ltd.

Manor Royal
Business District covers an area of 240 hectares adjacent to Gatwick Airport.
The Business District provides 8 million square feet of commercial space and is
home to more than 500 companies and 30,000 employees. As such it is one of the
biggest business areas in the south east.

The future
direction of Gatwick Airport has a direct bearing on the future of the Manor
Royal Business District. The response of MRBD Limited recognises the merits of
an expanded Gatwick Airport while highlighting a number of areas of concern
where further work is required.

Our response
expresses the view that expanding Gatwick Airport has a number of advantages
over those proposed for Heathrow and represents a much more deliverable option.
However, our support to expanding Gatwick Airport is conditional on those
issues highlighted being adequately addressed, which at the moment they are
not. Our support, therefore, can only be conditional subject to further work
and analysis.

Q1: What conclusions, if any, do you draw
in respect of the three short-listed options?

On balance,
based on the findings of the Commission, we acknowledge the advantages of
expanding Gatwick Airport as it represents a more deliverable and cost-effective
option for increasing capacity in London and the South East. This is notwithstanding that part of the
business district, equating to approximately one million square feet of
commercial space, would be lost by the planned second runway.

This is a
matter of great concern to MRBD Limited and we have already (with others)
entered into discussions with Gatwick Airport Limited as to how this impact can
be ameliorated.

However, the
importance of Gatwick Airport as an economic driver is critical at a local,
regional and national level and MRBD Limited on balance supports Gatwick
Airport Limited's proposal to expand the airport and deliver two world class
airports serving London and the UK - but only subject to certain conditions
being met.

Since the
airport was purchased by Global Investment Partners in 2009, we have been
encouraged by the sizeable investments and improvements made to the
infrastructure and operations at Gatwick Airport, which have transformed the
Airport and enhanced its reputation.

Expansion at
Gatwick will increase access to destinations worldwide, enabling our local,
world-class companies to expand their operations and be retained in the area
leading to a boost international trade and job creation.

We believe
that Gatwick's plan is relatively simple and can be delivered in a more
acceptable timescale with lower cost to the public purse than the Heathrow
option.

However, we
do have concerns relating to a number of matters that we would ask the
Commission to take into account and on which we believe more clarity is
required.

Q2: Do you have any
suggestions for how the short-listed options could be improved?

Availability
of Land for Employment and Housing

We are particularly concerned about the provision of land to accommodate
the perceived demand for housing and commercial property in the Crawley and
Gatwick Diamond area.

We believe further
work is required to adequately assess both current and future needs in relation to land supply which is already at a tipping point.

We believe more work is needed to ensure that land can be appropriated
in the area, and the demand created for additional land to accommodate new
residents and businesses, is planned carefully to avoid excessive in-commuting,
increased congestion and increased property costs. In our view the Commission
has taken a far too simplistic view of how these demands can be met and not
properly taken into account the shortage of land to meet current and predicted
levels of demand without a second runway.

Impact on business premises and businesses

Consequently, Manor Royal Business District is directly affected by Gatwick
Airport's plans for expansion albeit we recognise that a negative impact may be
inevitable. However, it is important that those businesses and their employees
that are directly affected receive relocation assistance as compensation for
disruption to their day-to-day operations - this assistance should not be
concentrated solely to land and property owners but should be extended to
leasehold tenants. At this stage, the Commission's assessment of land supply
issues and how they may be addressed appear under-researched and insufficiently
evidenced.

Road and
Rail infrastructure

We believe
that firm commitments, based on valid and detailed research, need to made, in
order to secure adequate investment for the delivery of improvements to road
and rail to meet the enlarged airport's travel consequences. Thus, one of the Gatwick
Diamond's core assets - it's connectivity by a variety of transport modes - is
less likely to be undermined.

The
Commission refers to the requirement for more detailed modelling of the local
road network to assess the impact on key junctions. From our perspective, it is imperative that
this is undertaken as a priority as some existing roads around the western perimeter
of Gatwick Airport are likely to be closed, resulting in a seriously negative
impact on congestion and journey times in and around Manor Royal Business
District. This will have a significant
adverse effect on many of the 30,000 people working on Manor Royal.

East-West
connectivity into Crawley and Manor Royal Business District is already
difficult at peak travel times and it is important this situation is not
exacerbated further. We are seeking reassurances
that this issue is addressed and for sufficient funds to be made available to
improve the local network and road junction operation.

Other Supporting
infrastructure

Inherent in
planning for new houses and business premises is the requirement for supporting
infrastructure, beyond and not restricted to transport infrastructure. There
appears to be little consideration of this and yet it is critical for
successful location management. As well as being a cornerstone of the New Town
movement upon which the modern town of Crawley is founded, the principles are
central to a decent quality of life socially, environmentally and economically.

Q3: Do you have any
comments on how the Commission has carried out its appraisal?

Economic
benefit

The Commission recognises the inherent difficulty with predicting future
patterns in aviation (hence the forecasting based on five different scenarios)
each leading to different possible futures for each airport and their
respective benefits for job creation and wider economic benefit. We would welcome some further insight or
clarity as matters develop as this uncertainty is unhelpful when the central
argument for expansion is about economic growth. Furthermore, it has direct implications for
the requirement for additional housing in the Gatwick Diamond area.

Q4: In your view, are
there any factors that have not been fully addressed?

Impact of
expansion at Heathrow

If Heathrow Airport
is recommended by the Commission as the preferred option for expanding airport
capacity in the South East, it is important to understand the implications for
Manor Royal Business District and the larger Gatwick Diamond area.

There are
concerns that the area would suffer huge negative impacts should this be the
preferred option. Currently, there is a lack of understanding amongst policy
makers, stakeholders, businesses and local communities about what might be done
to mitigate this impact and construct a different future without an expanded
Gatwick. This is not addressed in the report.
For example, would safeguarded land at Gatwick be released for commercial
and residential development? A decision
to expand Heathrow while retaining safeguarded land as a reserve would be
detrimental to the Gatwick Diamond area, effectively starving it of the
opportunity to grow. This scenario is
not discussed within the report.

Connectivity
between Gatwick and Heathrow Airports

Of equal
importance to the business community, many of whom trade internationally, is
the connectivity between Gatwick and Heathrow Airports. This point is of relevance whichever scenario
is adopted. The speed of access between the two airports needs
improvement for the benefit of UK Plc. Again, this is not addressed in the
report.

Q8: Do you have any
other comments?

Jobs and
commuting

The
Commission correctly recognises that there is a reasonable level of commuting to
jobs outside the area e.g. to London and surrounding areas. However, we question
the extent that an expanded Gatwick would reduce this trend by encouraging
people to take up employment at the Airport and within the local area. This clearly impacts on the area's housing
and other infrastructure needs and we therefore believe this requires more
careful evaluation.

Area-wide
Governance

If Gatwick
Airport is recommended by the Commission as the preferred option for expanding
airport capacity in the South East, we strongly urge the Commission to petition
Government to obtain additional economic impact studies.
An expanded
Gatwick Airport will have a positive impact on the locality, in that it will bring
with it heightened status and profile for the Gatwick Diamond region. This further
emphasises the importance of new responsibilities in terms of ‘place management'
and governance. However, this will need
to be managed efficiently to avoid unnecessary bureaucratic delays and
compromises. The structures for government in place locally must be robust
enough to manage and take decisions on an area-wide basis.
We therefore
recommend that a governance model should be established to deliver the
appropriate environment for robust accountability to satisfy stakeholders
across the region.

The
importance of making a decision

Finally, we strongly
encourage the Commission to impress on the Government and the Opposition the
importance of making a decision. The debate about airport expansion has already
been long running without any conclusion and a number of seemingly ‘false
starts'. We trust that the Commission,
in making its recommendation, will emphasise the need for the decision to be
final and delivered within a defined timescale.

Yours sincerely

Trevor Williams, ChairmanSteve Sawyer, Executive DirectorManor Royal Business District Limited

SUBMISSION MADE TO THE AIRPORTS COMMISSION BY MRBD LIMITED WAS SENT ELECTRONICALLY ON 30 JANUARY 2015